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2. Beginning at least as early as January 1997, until at least as late as March 2006,
the exact dates being unknown to the Grand Jury, coconspirators of the defendants joined,
entered into, and engaged in a combination and conspiracy to suppress and eliminate competition
by fixing prices, reducing output, and allocating market shares of color display tubes ("CDTs") to
be sold in the United States and elsewhere. The combination and conspiracy engaged in by the
defendants and coconspirators was in unreasonable restraint of interstate and foreign trade and
commerce in violation of Section 1 of the Sherman Act (15 U.S.C. § 1).

3. Defendant SEUNG-KYU LEE joined and participated in the conspiracy from at
least as early as January 2000 and continuing until at least December 2005.

4. Defendant YEONG-UG YANG joined and participated in the conspiracy from at
least as early as June 2003 and continuing until at least March 2006.

5. Defendant JAE-SIK KIM joined and participated in the conspiracy from at least as
early as June 2003 and continuing until at least March 2006.

6. The charged combination and conspiracy consisted of a continuing agreement,
understanding, and concert of action among the defendants and coconspirators, the substantial
terms of which were to agree to fix prices, reduce output, and allocate market shares of CDTs to
be sold in the United States and elsewhere for use in computer monitors and other products with
similar technological requirements.

II.MEANS AND METHODS OF THE CONSPIRACY

7. For the purpose of forming and carrying out the charged combination and
conspiracy, the defendants and coconspirators did those things that they combined and conspired
to do, including, among other things:

(a) attending meetings and engaging in conversations and communications in
Taiwan, Korea, Malaysia, China, and elsewhere to discuss the prices,
output, and market shares of CDTs;

(b) agreeing during those meetings, conversations, and communications to
charge prices of CDTs at certain target levels or ranges;

(c) agreeing during those meetings, conversations, and communications to
reduce output of CDTs by shutting down CDT production lines for certain
periods of time;

(d) agreeing during those meetings, conversations, and communications to
allocate target market shares for the CDT market overall and for certain
CDT customers;

(f) implementing an auditing system that permitted coconspirators to visit each
other's production facilities to verify that CDT production lines had been
shut down as agreed;

(g) authorizing and approving the participation of subordinate employees in the
conspiracy;

(h) issuing price quotations and reducing output in accordance with the
agreements reached; and

(i) taking steps to conceal the conspiracy and conspiratorial contacts through
various means.

III.DEFENDANTS AND COCONSPIRATORS

8. Defendant SEUNG-KYU LEE is or was a resident of Korea. From at least as early
as January 2000 and continuing until at least December 2005, SEUNG-KYU LEE was employed
by Company A and later by Company B. Company B was a joint venture formed in
approximately 2001 between Company A and Company C. Beginning around 2004, SEUNG-KYU LEE was responsible for CDT sales for Company B. During the period covered by this
Indictment, Company A was a Korean company, and Company B was a company incorporated in
the Netherlands, headquartered in Hong Kong, and engaged in the business of producing and
selling, among other things, CDTs to customers in the United States and elsewhere.

9. Defendant YEONG-UG YANG is or was a resident of Korea. From at least as
early as June 2003 and continuing until at least March 2006, YEONG-UG YANG was employed
by Company B and, beginning around 2004, was responsible for CRT sales for Company B.
During the period covered by this Indictment, Company B was a company incorporated in the
Netherlands, headquartered in Hong Kong, and engaged in the business of producing and selling,
among other things, CDTs to customers in the United States and elsewhere.

10. Defendant JAE-SIK KIM is or was a resident of Korea. From at least as early as
June 2003 and continuing until at least March 2006, JAE-SIK KIM was employed by Company D
and, beginning around 2002, was CRT Sales Division Head for Company D. During the period
covered by this Indictment, Company D was a Korean company engaged in the business of
producing and selling, among other things, CDTs to customers in the United States and elsewhere.

11. Various corporations and individuals not made defendants in this Indictment
participated as coconspirators in the offense charged in this Indictment and performed acts and
made statements in furtherance of it.

12. Whenever in this Indictment reference is made to any act, deed, or transaction of
any corporation, the allegation means that the corporation engaged in the act, deed, or transaction
by or through its officers, directors, employees, agents, or other representatives while they were
actively engaged in the management, direction, control, or transaction of its business or affairs.

IV.TRADE AND COMMERCE

13. CDTs are a type of cathode ray tube. Cathode ray tubes consist of evacuated glass
envelopes that contain an electron gun and a phosphorescent screen. When electrons strike the
screen, light is emitted, creating an image on the screen. CDTs are the specialized cathode ray
tubes manufactured for use in computer monitors and other products with similar technological
requirements.

14. During the period covered by this Indictment, Company B, Company D, and
coconspirators sold and distributed substantial quantities of CDTs in a continuous and
uninterrupted flow of interstate and foreign trade and commerce to customers located in states or
countries other than the states or countries in which Company B, Company D, and coconspirators
produced CDTs. In addition, payments for CDTs traveled in interstate and foreign trade and
commerce.

15. During the period covered by this Indictment, the business activities of the
defendants and coconspirators related to the sale and distribution of CDTs that are the subject of
this Indictment were within the flow of, and substantially affected, interstate and foreign trade and
commerce.

V.JURISDICTION AND VENUE

16. The combination and conspiracy charged in this Indictment was carried out, in
part, in the Northern District of California, within the five years preceding the filing of this
Indictment.